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|Global Tax Policy and Controversy Briefing #19||Global Tax Policy and Controversy Briefing features an interview with Mike Williams, Chair of the OECD’s multilateral instrument (MLI) group, who gave a progress report on the MLI and the road ahead; articles on the European Commission’s Common Consolidated Corporate Tax Base proposal and how digital tax administration is creating new challenges for companies’ tax and finance departments; country updates from Hong Kong, Israel, Singapore, the UK and the US, as well as new G20 tax rates table showing the latest corporate, personal and VAT/GST rates.||Publication||20161230June 2017|
|2017 Tax Risk and Controversy Study Series: Tax steps into the light||The new Tax Risk and Controversy report “Tax steps into the light” is the first in a five part series examining highlights from a survey of 901 tax and finance executives representing more than 17 industries in 69 jurisdictions. The first report explains that the business of tax is undergoing a fundamental shift on a global scale.||Publication||20161230June 2017|
|Luxembourg explains its positions on Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS||On 7 June 2017, Luxembourg signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (the MLI) during a signing ceremony hosted by the OECD in Paris. Luxembourg has made partial or full reservations against a number of the articles of the MLI. The most important changes that will affect all of Luxembourg’s tax treaties relate to the introduction of a principal purpose test and an amendment of the preamble that states that the relevant tax treaty is not intended to create opportunities for non-taxation or reduced taxation.||Tax Alert||20161230June 2017|
|Are you ready to apply for your 2016 VAT refund?||Are you ready to apply for your 2016 VAT refund?||Tax Alert||20161230June 2017|
|Double Tax Treaty between Luxembourg and Cyprus||On 8 May 2017, Luxembourg signed the first Income and Capital Tax Treaty with Cyprus. This signature is an important event since Cyprus is the last EU Member State with which Luxembourg has no Double Tax Treaty yet. With the signature of this new Treaty, Luxembourg further expands its extensive Double Tax Treaty network and strengthens its economic and commercial relations with Cyprus.||Tax Alert||20161230June 2017|
|Incompatibility of the 3% contribution with article 4-1 of the parent-subsidiary directive||In a decision dated 17 May 2017, the CJEU ruled that the 3% contribution on distributed profits was contrary to article 4-1 of the parent-subsidiary directive, insofar as the base for assessment of this contribution is composed of dividends distributed by subsidiaries that are residents of other Member States.||Tax Alert||20161230May 2017|
|Dutch Government launches internet consultation to amend the Dividend Withholding Tax Act||Following its letter published on 20 September 2016 regarding the proposed alignment of the Dutch dividend withholding tax treatment of profit distributions made by Dutch Cooperatives and limited liability companies, on 16 May 2017, the Dutch Ministry of Finance launched an internet consultation and published its proposed amendments to existing corporate income tax and withholding tax legislation.||Tax Alert||20161230May 2017|
|CJEU rules on rights of requested party with respect to exchange of information||On 16 May 2017, the Grand Chamber of the Court of Justice of the European Union (CJEU) released its decision on the case Berlioz Investment Fund SA v. Directeur de l’administration des Contributions directes (C-682/15). With respect to an exchange of information request, the CJEU ruled that the requested party (Berlioz) has the right to appeal the request for information as well as the penalties imposed due to the failure to provide information. Unless the irrelevance of the required information is demonstrated, the foreseeable relevance should not be denied by the courts of the requested State.||Tax Alert||20161230May 2017|
|Luxembourg transfer pricing legislation at a glance||With the introduction of article 56bis LITL, the Circular regarding intra-group financing and CbC reporting, Luxembourg’s transfer pricing legislation has gone through quite some changes.||Tax Alert||20161230May 2017|
|Independent Group of Persons: Decision by the EUCJ against Luxembourg in respect of the application of the VAT exemption||The decision released by the EUCJ against Luxembourg confirmed that the implementation into the Luxembourg VAT Law of the exemption scheduled by the EU VAT Directive for Independent Group of Persons to its members is not in line with the Directive and Regulation.||Tax Alert||20161230May 2017|
|The 2017 Tax Policy Outlook report shows that global tax reforms and sustained weak economic growth continue to disrupt the global tax landscape.||The 2017 Tax Policy Outlook report shows that the long-term trend for countries to pursue a “low-rate, broad-base” business tax strategy remains strong in 2017 and that, at the same time, many countries now also seem to be responding to criticisms of harmful tax practices by either increasing existing business incentives or introducing entirely new incentives as a way to remain competitive.||Brochure||20161230April 2017|
|AG Opinion on the VAT exemption for cost sharing (C-616/15, Commission vs Germany)||On 5 April 2017, the Court of Justice of the European Union released the advocate general’s opinion concerning the operation of the cost sharing VAT exemption in the case European Commission v Federal Republic of Germany (C-616/15). This case constitutes the fourth episode of the saga around the analysis of the scope and extent of application of the provisions of Article 132, 1. (f) of the Council Directive 2006/112/EC (the VAT Directive).||Tax alert||20161230April 2017|
|Norwegian tax authorities approve refund claims of US RICs for dividend withholding tax||While the Norwegian tax authorities previously have denied treaty benefits to United States regulated investment companies (RICs) based on a 2008 position of the Norwegian Ministry of Finance, they recently approved reclaims from several US RICs for dividend withholding tax.||Tax alert||20161230March 2017|
|Dutch Supreme Court refers preliminary questions on Dutch dividend withholding tax to CJEU||The Dutch Supreme court asked for a preliminary ruling from the Court of Justice of the European Union in two cases that relate to a German and UK resident investment fund that both filed several Dutch dividend withholding tax refund requests to the Dutch tax authorities on the basis of the free movement of capital laid down in Article 63 of the Treaty on the Functioning of the EU.||Tax alert||20161230March 2017|
|AG Opinions on EU VAT cost sharing exemption||On Wednesday, 1 March 2017, the Court of Justice of the European Union (CJEU) released two Advocate General (AG) Opinions concerning the operation of the EU VAT cost sharing exemption (CSE). Across the EU, Member States have interpreted and implemented the CSE rules differently, leading to complexities, particularly where services flow cross-border. In summary, the AG has, amongst other points, opined that the CSE cannot apply to financial services institutions and that the exact reimbursement test is automatically failed where transfer pricing requires a “mark-up”.||Tax alert||20161230March 2017|
|Luxembourg Tax Memento 2017||The Luxembourg Tax Memento 2017 pocket-guide summarizes the main Luxembourg tax rates and taxation principles applicable for both corporate and individual taxpayers.||Publication||20161230March 2017|
|Tax Insights #18 – Seeking Certainty||In this edition of Tax Insights, we look at the recent developments in tax, the unique challenges they bring, and what steps are needed to ensure consistency in the evolving tax world.||Tax Insights||20161230March 2017|
|Luxembourg releases new circular on transfer pricing for companies carrying out intra-group financing activities||On 27 December 2016, the Luxembourg Tax Authorities issued an administrative Circulaire reshaping the transfer pricing framework for companies carrying out intra-group financing activities in Luxembourg. The Circular provides additional guidance in terms of substance and transfer pricing requirements in line with the OECD Guidelines. |
It refers to the new article 56bis introduced into the Luxembourg Income Tax Law by the Budget Law of 23 December 2016 which aims to incorporate the concept of the arm’s length principle, based on the OECD principles as revised by Actions 8-10 of the OECD BEPS Action Plan, into the local legislation.
The new Circular will replace Circulaires n°164/2 of 28 January 2011 and n°164/2bis of 8 April 2011 effective as of 1 January 2017.
|Tax Alert||20161230December 2016|
|Luxembourg Tax Authorities extend Country-by-Country notification deadline and clarify filing procedure||On 27 December 2016, the Law of 23 December 2016 on Country-by-Country reporting (the CbCR Law), implementing Directive 2016/881/EU of 25 May 2016 with respect to the mandatory automatic exchange of information in the field of taxation, was published in Luxembourg’s Official Gazette. |
On the same date and as expected, the Luxembourg Tax Authorities extended the deadline for the first notification to 31 March 2017 and clarified administrative issues regarding Country-by-Country reporting (CbCR) notifications (e-filing).
|Tax Alert||20161228December 2016|
|Luxembourg's Parliament adopts 2017 Budget Law with new article on arm's length principle in line with Actions 8-10 of OECD BEPS Action Plan||On 22 December 2016, the Luxembourg Parliament voted and approved draft law n°7050 related to the budget law 2017, including a new article on arm’s length principle in line with Action 8-10 of OECD BEPS.||Tax Alert||20161223December 2016|
|Luxembourg’s Parliament adopts draft law on Country-by-Country Reporting||On 13 December 2016, the Luxembourg Parliament adopted draft law n°7031 on Country-by-Country reporting, implementing Directive 2016/881/EU of 25 May 2016, with respect to the mandatory automatic exchange of information in the field of taxation.||Tax Alert||20161104December 2016|
|Luxembourg’s Parliament adopts Law on tax reform 2017 - A review of the corporate tax measures||On 14 December 2016, the Luxembourg Parliament voted and approved draft law n°7020 on the tax reform 2017, introducing amendments in the field of corporate and individual taxation, as well as in the field of indirect taxes.||Tax Alert||20161104December 2016|
|Luxembourg’s Law on tax reform 2017 has VAT implications||On 14 December 2016, the Luxembourg Parliament voted and approved draft law n°7020 on the tax reform 2017, introducing a series of VAT changes.||Tax Alert||20161104December 2016|
|Tax Insights: transformation and innovation||With so much innovation happening, it’s a challenging and exciting time to be involved in tax. We explore the changes yet to come.||Tax Insights||20161104October 2016|
|Global tax policy and controversy briefing - Issue 18||This edition focuses on Brexit, the G20’s new focus on growth and certainty, EU developments and India’s new GST regime.||Publication||20161104October 2016|
|Luxembourg introduces draft budget law 2017 including new article on arm’s length principle in line with Actions 8-10 of OECD BEPS Action Plan||On 12 October 2016, the Luxembourg Government introduced in Parliament draft law n°7050 on the budget for the year 2017 (the Budget Law). The Budget Law foresees the introduction of a new article 56bis in the Luxembourg Income Tax law (ITL) that aims to clarify the concept of the arm’s length principle. |
Furthermore, and to comply with European legislation, the Budget Law foresees some amendments regarding the real estate tax regime for charitable and non-profit organizations and the tax collection for EU nonresidents willing to establish their residence in Luxembourg. The Budget Law also sets forth an amendment to the Value Added Tax (VAT) regime for small and medium-sized companies.
|Tax alert||20161007October 2016|
|Directors’ remuneration – their tax treatment in Luxembourg||The Luxembourg VAT administration issued Circular n° 781 on September 30, 2016 which specifies the applicable VAT treatment applicable to directors’ fees. According to the Circular, the activity performed by directors qualifies as an economic activity in the sense of the VAT legislation, irrespective of the status of the director being a legal person or an individual. The services performed by directors thus fall within the scope of VAT.||Tax alert||20161007October 2016|
|Economie Digitale : Nouveaux défis en matière de TVA||Les évolutions considérables de l’économie numérique auxquelles nous assistons défient les règles en matière de taxe indirecte, engendrant le doute pour les assujettis à la taxe et créant de nouvelles préoccupations pour les administrations fiscales.||Press Article||20160819September 2016|
|Implications of the Tax Reform 2017 for Luxembourg VAT||On 26 July 2016, the Minister of Finance submitted to the Luxembourg Parliament Draft law no. 7020 that introduces the main features of the tax reform for 2017. The draft law, in line with the measures already announced during a press conference held on 29 February 2016, contains a series of VAT changes.||Tax alert||20160819August 2016|
|Digital Services, mobile payment and VAT||The development of the technology affects not only the way that goods and services are rendered but also how these supplies are paid for by customers. Today, payments can be made any time, using any device, by customers located anywhere.Cashless and virtual payments are increasing in popularity. The most common payment instruments used as alternatives to cash are credit and debit cards, but other means are quickly spreading such as digital currencies, e-payments including M-payments,…This situation is rendered more complex from a VAT point of view because each mean of payment, from the traditional to the digital, has its own features and specific facts, possibly resulting in very different VAT treatments.The consequences for the economic operators (e.g., banks, telecoms companies etc) may lead fully taxable businesses to fall within the scope of the VAT exemption. In addition financial institutions will need to understand the new challenges around the supply of e-services and associated considerations.||Tax alert||20160819August 2016|
|Luxembourg introduces draft law on country-by-country reporting||On 2 August 2016, the Luxembourg Government submitted draft law n°7031 on country-by-country (CbC) reporting (the draft law) to the Luxembourg Parliament. The draft law is in accordance with a European Union (EU) Directive of 25 May 2016 requiring all EU Member States to implement a CbC reporting obligation in their national legislation. If adopted, all Luxembourg tax resident entities that are part of a multinational group and meet certain financial thresholds will need to comply with the CbC reporting requirements for financial years starting on or after 1 January 2016.||Tax alert||20160819August 2016|
|Luxembourg draft law on tax reform 2017 is introduced in Parliament||On 26 July 2016, draft law n°7020 (the draft law) in relation to the tax reform 2017 was introduced in the Luxembourg Parliament. The draft law covers corporate tax, indirect tax and individual tax measures. It essentially includes the measures already announced during a press conference held on 29 February 2016, with some adjustments and additional elements following the observations and suggestions made by the different social partners involved in the preparation of the 2017 tax reform. This Alert summarizes the corporate tax measures included in the draft law.||Tax alert||20160726August 2016|
|All you need to know about the Reserved Alternative Investment Fund (RAIF)||On 14 July 2016, the Luxembourg Parliament adopted the bill n°6929 which introduces a new type of alternative investment fund in Luxembourg: the reserved alternative investment fund (RAIF – or fonds d’investissement alternative réservé, FIAR). |
This law has been published in the Luxembourg official gazette, the Mémorial A, on 28 July 2016.
|The modernization of the Luxembourg company law||After several years, the long-awaited Bill of Law n°5730 amending and modernizing the Luxembourg Law of 10 August 1915 on commercial companies, as amended from time to time, was adopted.On 13 July 2016, the Luxembourg Parliament voted the Bill of Law n°5730. The New Law recognizes and provides a legal basis for certain market practices well established among Luxembourg professionals. Furthermore, the Luxembourg legislator has aimed to develop new legal instruments to attract investors, multinationals and private equity firms.||Regulation, Financial Accounting and Reporting alert||20160726July 2016|
|CJEU decision on VAT recovery of branch network support costs||The ESET case (C-393/15) focuses on business’s ability to recover VAT on global and branch support costs. This is an important topic, particularly for companies which operate via a complex branch network.||Tax alert||20160721July 2016|
|Dig up the road once||A practical guide of the regulatory agenda applicable to Luxembourg financial institutions which seeks to provide an overview of the regulatory framework in the financial sector while focusing specifically on wealth and asset management, banking and insurance industries. |
The Overview incorporates the regulations issued by Luxembourg, the European Union and selected international regulators and industry bodies.
|EU publishes opening decision on State aid investigation into US branch structure||In December 2015, the European Commission announced that it was investigating two Luxembourg rulings of a multinational company involving a Luxembourg company with US and Swiss branches. On 6 June 2016, a non-confidential version of the letter was published, in which the Commission formally informed Luxembourg of its preliminary conclusion that the rulings constitute State aid.||Tax alert||20160621June 2016|
|European Commission publishes final decision finding Luxembourg granted State aid in transfer pricing case||On 9 June 2016, the European Commission published its final decision in the State aid investigation case relating to Luxembourg, rendered on 21 October 2015. The Commission determined that Luxembourg granted illegal State aid to a Luxembourg-resident company, which forms part of a multinational company group.||Tax alert||20160620June 2016|
|Think global, act global – Why middle market companies should build the tax function of the future, today||This new EY thought leadership report is based on a Global Compliance and Reporting (GCR) survey of 270 middle market companies in 26 markets. It focuses not only on GCR process and strategy, but on wider tax function management, and includes excellent findings, recommendations and calls-to-action.||Brochure||20160527May 2016|
|Luxembourg: the gateway for Islamic finance and the Middle East||Islamic finance is one of the fastest growing areas of the global financial services industry. The spread of Islamic finance into western markets demonstrates that it is now being viewed by investors, financial institutions and regulators as a viable alternative to conventional products.||Brochure||20160526May 2016|
|Global taxation of intellectual property||This EY Top of Mind publication explores the issues technology companies are facing due to new tax policies.||Brochure||20160526May 2016|
|Financial Services - connected? Responding to the new regulatory environment||The Financial Services – connected? is EY Luxembourg’s publication responding to the regulatory environment, applicable to the wealth and asset management, banking and insurance industry from a Luxembourg perspective. Financial Services – connected? will help you to be informed about the recent regulatory developments, the actions to be taken and the solutions provided by our expert services.||Brochure||20160525May 2016|
|Managing indirect taxes in the digital age||As the digital economy challenges existing indirect tax rules, our comprehensive report offers insights for businesses operating successfully in this new tax environment.||Brochure||20160525May 2016|
|2016 Worldwide Corporate Tax Guide||The 2016 Worldwide Corporate Tax Guide summarizes the corporate tax systems in 162 jurisdictions and each chapter provides at-a-glance information, as well as details, on the taxes on corporate income and gains, determination of trading income, other significant taxes, miscellaneous matters (including foreign-exchange controls, debt-to-equity rules, transfer pricing, anti-avoidance legislation, etc.) and treaty withholding tax rates.||Tax Guide||20160518May 2016|
|2016 Worldwide VAT, GST and Sales Tax Guide||This guide summarizes the value-added tax, goods and services tax and sales tax systems in 114 countries and the European Union. Use the map or the menu to see the guide’s information for a country.||Tax Guide||20160512May 2016|
|Indirect Tax Briefing: global developments||Gain insight on indirect tax developments around the world including the impacts, opportunities and obligations that are resulting from digitalization.||Brochure||20160430April 2016|
|Luxembourg introduces mandatory exchange of information on cross-border rulings in accordance with EU Directive||Information on cross-border rulings and advance pricing agreements issued by European Union (EU) Member States will be automatically exchanged with other EU Member States from 1 January 2017. The Luxembourg Government has now adopted and transferred to Parliament for approval, a draft law transposing the Directive into Luxembourg domestic law.||Tax alert||20160430April 2016|
|Digital Tax Developments Review||This second edition features an article discussing the role of the tax director in helping his or her enterprise adapt to the new digital reality, and a round table discussion of EY professionals in which they highlight what digital transformation means to a business and how leaders can get to grips with it. It also includes a coverage of the continuing legislative and policy action related to digital taxation around the world.||Brochure||20160429April 2016|
|Are you ready to apply for your 2015 VAT refund?||Foreign VAT incurred on expenses is often perceived as a cost directly impacting the organization’s profit. |
However, you may be able to recover VAT incurred in countries where you are not established or VAT registered, provided you comply with the rules.
|Tax alert||20160401April 2016|
|New platform for the e-filing of VAT returns||“eTVA” is a specific on-line system used by the Luxembourg VAT Authorities, enabling taxpayers to file VAT returns and other documents such as European Sales Lists for goods and services in electronic format.||Tax alert||20160401April 2016|
|Banques dépositaires et application de la TVA||A la suite de l'introduction en droit luxembourgeois de nouvelles règlementations, les banques dépositaires luxembourgeoises ont vu leurs responsabilités légales et financières s'accroître au cours de ces dernières années, avec pour conséquence un impact sur le traitement TVA de leurs rémunérations.||Press Article||20160330March 2016|
|2016 Global Tax Policy Outlook||We highlight government proposals for new legislation, an overview of global tax policy trends and individual countries' policy developments.||Brochure||20160330March 2016|
|How BEPS fits in with the EU’s tax agenda||Klaus von Brocke and Jurjan Wouda Kuipers, EY tax professionals, in collaboration with International Tax review, look at how BEPS recommendations interact with EU tax laws.||Press Article||20160330March 2016|
|BEPS Is Broader Than Tax: Practical Business Implications of BEPS||In collaboration with International Tax Review, we provide readers with practical guidance on how to handle the implications of BEPS on key business functions.||Press Article||20160330March 2016|
|Luxembourg releases broad outline of 2017 tax reform||At a 29 February 2016 press conference given by Luxembourg’s Prime Minister Xavier Bettel, Vice-Prime Minister Etienne Schneider, Minister of Finance Pierre Gramegna and Minister of Justice Felix Braz, some long-awaited details regarding the 2017 tax reform were released.||Tax Alert||20160222March 2016|
|Tax Insights: the rising importance of tax talent||See our latest edition to learn how leading companies are recruiting and developing tax talent, to understand how tax is being transformed worldwide and more.||Tax Insights||20160301March 2016|
|Indirect tax developments in 2016||Our latest publication identifies global developments in indirect taxes, including value-added tax (VAT), goods and services tax (GST), consumption taxes, excise duties, customs duties, insurance premium tax (IPT) and environmental taxes. We highlight indirect tax changes introduced in more than 100 jurisdictions in recent months and those expected in 2016 and beyond. We also include world maps that provide a snapshot of where the changes are taking place.||Tax Alert||20160222February 2016|
|2015-16 Worldwide Transfer Pricing Reference Guide||This guide summarizes the transfer pricing rules and regulations adopted by 117 countries and territories.||Tax Guide||20160222February 2016|
|Standard Audit File for Luxembourg VAT purposes (February 2016)||In 2005, under the auspices of the Organisation for Economic Cooperation and Development (OECD), the Forum on Tax Compliance sub-group released a guidance note concerning the Standard Audit File. This document provided for a detailed and technical description of the Standard Audit File for tax compliance auditing purposes (SAF-T). In brief, the SAF-T is an electronic file containing reliable accounting data exportable from an original accounting system and easily readable by Tax Authorities for tax audit purposes.||Tax Alert||20160218February 2016|
|Luxembourg Parliament approves 2016 tax measures||In December 2015, the Luxembourg Parliament approved several draft laws that amended the tax legislation for the year 2016 in important areas such as net wealth tax, the intellectual property regime and the participation exemption.||Tax alert||20160127January 2016|
|Global sustainability taxes||Discover which three areas of tax policy can help CFOs and tax directors navigate through environmental and sustainability changes happening today.||Brochure||20151001January 2016|
|When the sharing economy knocks, how will you answer?||Disruptive technologies such as cloud computing and mobile are creating a sharing economy. Explore how these new business models work and their benefits and challenges.||Brochure||20151001January 2016|
|TradeWatch: December 2015||On 4 October 2015, the ministers of the 12 Trans-Pacific Partnership (TPP) countries announced that they had reached agreement on terms.||Brochure||20151001December 2015|
|CRS - Luxembourg Law enacted||On 18 December 2015, the Luxembourg Law on the automatic exchange of financial account information in the field of taxation (the CRS Law) was enacted. The Law aims to introduce the Common Reporting Standard (CRS), developed by the Organization for Economic Co-operation and Development (OECD), into Luxembourg law and is applicable 1 January 2016.||Tax alert||20151204December 2015|
|Luxembourg Tax Authorities issue guidance on net wealth tax reduction regime||On 19 November 2015, the Luxembourg Tax Authorities issued circular letter I. Fort. n° 47bis (Circular). The Circular follows the 2014 introduction of the annual determination of net wealth tax (NWT) and the amendments to the mechanism for obtaining a NWT reduction. The Circular provides further guidance on this amended NWT regime. It applies for the first time to the NWT’s “unitary value” determination as at 1 January 2015.||Tax alert||20151204December 2015|
|Luxembourg Government submits new tax measures for 2016 to address changing tax environment||Tax - Luxembourg |
Recently, the Luxembourg government has submitted several draft laws for processing within Parliament. Once enacted, they will amend the existing tax legislation for the year 2016 in important areas such as net wealth tax, the intellectual property regime and the participation exemption.
|Tax alert||20151104October 2015|
|Indirect Tax Briefing #12||In our latest issue, we explore how megatrends such as transparency, technology and talent are shaping the global indirect tax landscape.||Brochure||20150801August 2015|
|Luxembourg publishes draft tax law reflecting EU-wide changes to parent-subsidiary directive||Tax - Luxembourg |
On 5 August 2015, Luxembourg published a draft law which, if adopted, will enact the amendments to the EU Parent-Subsidiary Directive, being the introduction of an anti-hybrid clause and an anti-abuse clause. Based on the draft law, these clauses will only apply within the intra-EU context.
|Tax alert||20150801August 2015|
|VAT free zone and auction houses - New VAT rules||VAT, GST & Other Sales Taxes - Luxembourg |
On 16 June 2015, the Luxembourg Parliament voted a new law amending the VAT law that will enhance the VAT regime applicable to transactions on works of art, collectors, items and antiques. It will also extend the benefit of the second hand VAT regime to auctions houses.
|CJEU judgment: Recovery of VAT by holding companies: Favorable decision of the Court||VAT, GST & Other Sales Taxes - Luxembourg |
On 16 July 2015 the Court of Justice of the European Union (CJEU) delivered its judgment in the joint cases Larentia +Minerva (C-108/14) and Marenave (C-109/14) regarding the right of holding companies to recover VAT when rendering management services to companies in which they hold shares. The CJEU recognized, in its judgment, that such companies could have a full right of recovery unless they also perform VAT exempt transactions.
|Tax Memento Luxembourg 2015||The Luxembourg Tax Memento 2015 pocket-guide summarizes the main Luxembourg tax rates and taxation principles applicable for both corporate and individual taxpayers. Its small-size format makes it a very useful and practical tool for the daily use, providing at a glance high-level information on Luxembourg taxes.||Brochure||20150626June 2015|
|Real estate funds: VAT exemption for fund management services||VAT, GST & Other Sales Taxes - Luxembourg |
The Advocate General of the Court of Justice considers in the "Fiscale Eenheid X" case that an entity set up by sevreal Dutch pension funds to invest in real estate properties could be considered as an investment fund for VAT and is capable to receive VAT exempt management services, he also considers that the concept of management services could include services related to the property such as searching tenants.
|Tax alert||20150602June 2015|
|Tax Insights: Tax policy in developing economies||From doing business in developing countries to managing tax controversy risks worldwide, our latest edition examines emerging tax policies and trends.||Tax Insights||20150521May 2015|
|VAT exemption applicable to intra-group services||A Grand-Ducal Decree dated 21 January 2004 as amended by the Grand-Ducal Decree dated 7 August 2012, as well as a circular dated 29 January 2004 clarify the VAT exemption regime for services supplied by independent groups of persons to their members.||Tax alert||20150518May 2015|
|Managing tax transparency and reputation risk||How can companies manage the reputational risks posed by the debate over who’s paying a “fair share” of taxes? We share six tactics.||Brochure||20150518May 2015|
|Worldwide Corporate Tax Guide||The chapters in this guide provide at-a-glance information, as well as details on the taxes on corporate income and gains, determination of trading income, other significant taxes, miscellaneous matters (including foreign-exchange controls, debt-to-equity rules, transfer pricing, controlled foreign companies and antiavoidance legislation) and treaty withholding tax rates. The content is based on information current as of 1 January 2015, unless otherwise indicated in the text of the chapter.||Tax Guide||201501012015|
|Worldwide Cloud Computing Tax Guide||Our interactive country map will help you gain insights into the cloud computing corporate tax regimes across the globe.||Tax Guide||201501012015|
|Worldwide Estate and Inheritance Tax Guide||This guide is designed to enable internationally positioned individuals to quickly identify the estate and inheritance tax rules, practices and approaches that have been adopted by 39 jurisdictions. Knowledge of these various approaches can assist individuals with their estate and inheritance tax planning, investment planning and tax compliance and reporting needs.||Tax Guide||201501012015|
|Global Oil and Gas Tax Guide||Exporting countries around the world are reconsidering how they tax the oil and gas industry in the wake of ongoing oil price volatility. Our 2015 Global Oil and Gas Tax Guide summarizes the oil and gas corporate tax regimes in 84 countries and includes a directory of our global oil and gas tax contacts.||Tax Guide||201501012015|
|TVA et droits de douane dans le secteur de la logistique||VAT, GST & Other Sales Taxes - Luxembourg |
Au cours de ces récentes années, la recherche de placements stratégiques a mené de nombreuses entreprises de logistique ainsi que des producteurs et distributeurs à structurer leurs chaînes d’approvisionnement via le Luxembourg. Il est certain que le Luxembourg présente un ensemble d’avantages à ce titre, en ce compris un ensemble de dispositions en matière TVA et douanière adaptées aux besoins commerciaux des entreprises.
|Securitization in Luxembourg - Our team – Our services||See how our leading integrated Securitization practice can understands and provides insights into the issues that those Securitization players need to address.||Brochure||20150408April 2015|
|Managing VAT through IT technology||Around the world, many countries are relying more and more on indirect taxes to finance their budgets.td>||Tax alert||20150326March 2015|
|CJEU judgment : The VAT liability of supplies of electronic books||VAT, GST & Other Sales Taxes - Luxembourg |
The Court of Justice of the European Union (CJEU) has today handed down its judgment concerning the reduced rate of VAT applied to electronic books (e-books) in France and Luxembourg. This alert sets out the background to the case and the implications of the decision.
|Tax alert||20150306March 2015|
|Luxembourg tax rulings 2.0||Tax - Luxembourg |
The Luxembourg practice of providing advance certainty in tax matters to taxpayers and investors wishing to set up operations in Luxembourg recently witnessed some interesting developments.
|Press article||20150301March 2015|
|Echange automatique d’informations : prenez vos dispositions dès maintenant||Tax - Luxembourg |
Le Luxembourg est depuis de nombreuses années un acteur moteur en matière d’échange d’informations. Des progrès considérables ont été effectués dans ce sens ces deux dernières années et sont planifiés pour les années à venir.
|Press article||20150105January 2015|
|Automatic exchange of information: the challenges to get it right||Tax - Luxembourg |
The changing transparency environment across European and many non-European States as well as increased client demands in relation to reporting and transparency have brought many financial institutions to measuring direct implications for them and to adapt their private client services.
|Press article||20150105January 2015|
|Luxembourg Tax ruling practice: adapt and prevail||Tax - Luxembourg |
The Luxembourg government is committed to continue providing investors with upfront legal security by way of tax rulings and advance pricing agreements for transactions and operations intended to be realized in Luxembourg.
|Tax alert||20150101January 2015|
|Worldwide R&D Incentives Reference Guide||This guide describes available benefits, eligibility, the application process and IP jurisdictional requirements in 34 countries. Use the map or the menu to see the guide’s information for a country.||Tax Guide||201412312014-2015|
|Worldwide Personal Tax Guide||This guide summarizes personal tax systems and immigration rules for expatriates in 162 jurisdictions.||Tax Guide||201412312014-2015|
|Worldwide Transfer Pricing Reference Guide||Summarizes the transfer pricing rules and regulations adopted by more than 110 jurisdictions.||Tax guide||201412312014|
|Luxembourg introduces legal framework for tax rulings and updates its transfer pricing rules||Tax - Luxembourg |
On 18 December 2014, the Luxembourg Parliament approved the draft law on the implementation of the first part of the “Package for the Future” released in the context of the 2015 Budget Law. Amongst other measures, the law will change the General Tax Law by including a provision dedicated to the tax ruling practice.
|Tax alert||20141201December 2014|
|The Luxembourg government comments on tax transparency and rulings||Tax - Luxembourg |
In a position paper on tax transparency and rulings published on 10 December 2014, the Luxembourg Ministry of Finance reaffirms its willingness to move towards enhanced transparency in tax matters.
|Tax alert||20141201December 2014|
|BEPS explained||Tax - Luxembourg |
BEPS is the current buzz-word in the international tax community. However, the potential implications of BEPS are so far-reaching that knowledge about it should not only be limited to tax experts. Nicolas Gillet, Partner and Transfer Pricing Leader at EY Luxembourg and Anja Taferner, Executive Director in EY Luxembourg’s International Tax Practice, give an overview of what BEPS would imply for the Luxembourg market.
|Press article||20141027October 2014|
|EU to investigate Amazon Tax Ruling for state and breach||Tax - Luxembourg |
The European Commission on October 7 formally launched an investigation into whether Amazon's Luxembourg subsidiary received a favorable transfer-pricing-related tax ruling that violates EU state aid rules.
|Press article||20141026October 2014|
|La nouvelle procédure d'échange automatique d'informations fiscales pour les salaires, pensions et tantièmes : quelles implications ?||Tax - Luxembourg |
La loi du 26 mars 2014 publiée au Mémorial le 31 mars dernier a transposé en droit luxembourgeois le dernier volet de la Directive 2011/16/UE relative à la coopération administrative dans le domaine fiscal, consistant en l’introduction d’une procédure d’échanges automatique d’informations fiscales.
|Press article||20141025October 2014|
|European Council extends the scope of Automatic Exchange of Information, adopts the OECD Common Reporting Standard and plans a repeal of the Savings Directive||On 14 October 2014, the European Council of Economic and Financial Affairs (ECOFIN) agreed to an amendment of the text of the Directive on Administrative Cooperation in the Field of Taxation 2011/16/EU (DAC).||Tax alert||20141024October 2014|
|The Luxembourg “Package for the Future”: Rebalancing public finances and overhauling the tax system||The Minister of Finance, M. Pierre Gramegna, has deposited on 15 October 2014 the “Budget of a new generation”. The Luxembourg Parliament will have to express its vote on the Budget Law 2015, but also on a multi-annual financial programming covering the period 2014-2018 and a draft law on the implementation of the first part of this “Package for the Future”.||Tax alert||20141001October 2014|
|How tax can impact the efficiency on an “in-house bank”?||Tax - Luxembourg |
Today, treasurers are responding to a changing environment. The demands on corporate treasury departments are constantly increasing and treasurers have to show how they manage financial resources and financial risks in an efficient way. These requirements for increased transparency and control have led to a global trend towards centralization of treasury activities.
|Press articles||20140902September 2014|
|La quantité fera place à la qualité||Tax - Luxembourg |
L’Europe tend à une harmonisation fiscale. Quels sont les enjeux pour l’attractivité du Luxembourg, qui a longtemps profité d’une fiscalité avantageuse pour développer son économie, attirer du business, engranger des recettes ? A l’avenir, répond Marc Schmitz, associé au sein du cabinet EY, il faudra privilégier la substance avant tout, et mieux se positionner pour continuer à attirer.
|Press articles||20140901September 2014|
|A more favorable Double Tax Treaty between Luxembourg and Czech Republic will take effect on 1 January 2015||International Tax - Luxembourg |
Luxembourg Parliament voted the draft law approving the Income and Capital Tax Treaty between Luxembourg and Czech Republic, signed on 5 March 2013.
|Tax alert||20140901September 2014|
|France and Luxembourg sign amendment to tax treaty impacting real estate holding structures||International Tax - Luxembourg |
On 5 September 2014, the Luxembourg and French Finance Ministers signed the fourth amendment to the double tax treaty concluded between France and Luxembourg. When it enters into force, this amendment will impact the tax treatment of various Luxembourg-France real estate holding structures.
|Tax alert||20140901September 2014|
|Annualisation of net wealth tax reporting to be introduced||Tax - Luxembourg |
Practical considerations aiming among others at accelerating the procedure of taxation have led the government to propose an annualisation of the net wealth tax reporting due by collective undertakings and thus to abandon the currently applicable system of triennial determination of the tax base.
|Tax Alert||20140901September 2014|
|Managing operational tax risk: survey highlights||International Tax - Luxembourg |
Finding the right people, processes and technology to manage record-to-report risks is no easy task. To consider how, see our survey’s leading practices.
|OECD issues Standard for Automatic Exchange of Information in Tax Matters||International Tax - Luxembourg |
On 21 July 2014, the Organisation for Economic Co-operation and Development (OECD) published the Standard for Automatic Exchange of Information in Tax Matters (the Standard).
|Tax alert||20140801August 2014|
|Double Tax Treaty between Luxembourg and Jersey, Guernsey and Isle of Man||International Tax - Luxembourg |
Luxembourg Parliament voted the draft law approving the Income and Capital Tax Treaties between Luxembourg and Jersey, Guernsey and the Isle of Man, signed respectively on 17 April 2013, 10 May 2013 and 8 April 2013.
|Tax alert||20140801August 2014|
|Double Tax Treaty between Luxembourg and Taiwan||International Tax - Luxembourg |
On 12 July 2014 Luxembourg ratified the first Income and Capital Tax Treaty with Taiwan and the Protocol signed on 19 December 2011. Taiwan has already signed the Treaty and the Protocol. Provided that the legal process is finalized within the course of this year, the Treaty will come into force as of 1 January 2015.
|Tax alert||20140701July 2014|
|Outward migration: deferral of exit taxes enacted||Tax - Luxembourg |
The law dated 26 May 2014 introduces the possibility to opt for a payment deferral of the tax normally due upon outward migration of (i) the statutory seat and place of effective management of a resident company and of (ii) a Luxembourg undertaking or permanent establishment to another Member state of the European Economic Area (EEA).
|Tax alert||20140601June 2014|
|Circular letter on the use of functional currency for tax purposes||Tax - Luxembourg |
On 16 June 2014, tax authorities have issued Circular letter L.G.-A n°60 providing a framework of rules for companies drawing their annual accounts in a foreign currency and wishing to declare their commercial result, as well as their taxable income, by converting the amounts determined in such foreign currency into euros (functional currency method).
|Tax alert||20140601June 2014|
|Double Tax Treaty between Luxembourg and Sri Lanka||International Tax - Luxembourg |
On 14 June 2013, Luxembourg ratified the first Income and Capital Tax Treaty with Sri Lanka, signed on 31 January 2013. The Treaty and its Protocol have entered into force on 11 April 2014. They will be applicable from 1 January 2015 onwards.
|Tax alert||20140601June 2014|
|Shanghai Free Trade zone||International Tax - Luxembourg|
On 27 September 2013, the State Council published the General Plan for China (Shanghai) Free Trade Zone (the Plan). The Plan sets out the guiding principles with respect to the general requirements, major tasks and measures, supervisory mechanism, tax policies and further opening up of the service sector in China (Shanghai) Free Trade Zone (the SHFTZ).
|Tax alert||20140501May 2014|
|La fin annoncée du report de l'imposition des plus-values immobilières pour les personnes physiques||Tax - Luxembourg|
En date du 20 février 2014, la Commission européenne a adressé au Luxembourg un avis motivé en matière de transfert de plus-values immobilières prévu par l’article 102 alinéa 8 de la loi concernant l’impôt sur le revenu.
|Tax alert||20140522May 2014|
|Alternative Taxation models for the VAT treatment of Business to Business Cross-Border Supplies of Goods||VAT, GST and other sales taxes - Luxembourg|
As indicated earlier the EU Commission has asked EY to conduct a survey regarding the possible solutions to improve VAT rules for the B2B cross border supply of goods. This survey is to be launched on 12 May 2014.
|Tax alert||20140425May 2014|
|EU Legislation: Have your say on future EU rules for the B2B cross border supply of goods||International Tax - Luxembourg|
Alternative Taxation models for the VAT treatment of Business to Business Cross-Border Supplies of Goods.
|Tax alert||20140425April 2014|
|Luxembourg and Mauritius signed new Protocol||International Tax - Luxembourg|
On 28 January 2014, the Governments of the Republic of Mauritius and the Grand Duchy of Luxembourg signed a Protocol amending the current Double Taxation Avoidance Agreement between the two countries. This Protocol will enter into force when both countries will have completed the ratification procedure.
|Tax alert||20140425April 2014|
|Managing indirect tax in the digital age||VAT, GST and other sales taxes - Global|
Multinational companies are handling large quantities of complex data about indirect taxes. We outline hands-on approaches that can help all that information.
|Agreement about the Savings Directive has been reached||International Tax - Luxembourg|
At the European Council meeting of 20th and 21st March, 2014, Luxembourg and the 27 other EU Member States came to a political agreement on the text of the directive amending the European Union Savings Tax Directive (Savings Directive).
|Tax alert||20140403March 2014|
|Protocol amending the Double Tax Treaty between Luxembourg and Korea||International Tax - Luxembourg |
Luxembourg and Korea signed a Double Tax Treaty on 7 November 1984 which entered into force on 26 December 1986. A Protocol amending this treaty has been signed on 29 May 2012. The Protocol entered into force on 4 September 2013 and has been effective since that date.
|Tax alert||20140319March 2014|
|VAT exemption for services to pension funds||VAT, GST and other sales taxes - Luxembourg |
The Court of Justice of European Union ruled that a defined benefit type pension fund could benefit from VAT exempt management services and gave indication regarding type of exempt as management or payment services.
|Tax alert||20140319March 2014|
|The Luxembourg Financial Connection - Issue 21||Luxembourg |
EY’s newsletter on regulatory, leading practices and market developments in the financial services industry from a Luxembourg perspective - including eight articles and covering over 100 new developments.
|Double Tax Treaty between Luxembourg and Laos||International Tax - Luxembourg |
On 14 June 2013 Luxembourg ratified the first Income and Capital Tax Treaty with Laos, signed on 4 November 2012. The Treaty will enter into force on 21 March 2014. The Treaty will be applicable from 1 January 2015 onwards.
|Tax alert||20140313March 2014||EU finalizes UCITS V negotiations - Upgrade of remuneration and depositary requirements||Tax - Luxembourg |
In February 2014, the European Union reached a compromise agreement on “UCITS V” – a Directive upgrading the UCITS requirements on remuneration policies, the depositary, as well as sanctions. The new requirements will have a substantial impact on many UCITS management companies and their depositaries.
|FSO alert||20140306March 2014|
|Protocol to the Double Tax Treaty between Luxembourg and Russia has entered into force||International Tax - Luxembourg |
As of 1 January 2014 the protocol to the Double Tax Treaty between Luxembourg and Russia has entered into force, meaning that the amendments to the Treaty have become applicable.
|Tax alert||20140205February 2014|
|Changes to the Customs law||Global Trade - Luxembourg |
The European Council has recently approved the Recast of the Union Customs Code (UCC). The adoption of the UCC marks an important step towards the adaptation of the EU Customs regulatory framework to the evolution of the technology.
|Tax alert||20140212January 2014|
|Double Tax Treaty between Luxembourg and Kazakhstan||Tax - Luxembourg |
On 16 May 2013 Luxembourg ratified the first Income and Capital Tax Treaty with Kazakhstan, signed on 26 June 2008, and the Protocol to this Treaty signed on 3 May 2012. The Treaty entered into force on 10 December 2013. The Treaty will be applicable from 1 January 2014 onwards.
|Tax alert||20140115January 2014|
|EU Savings Directive reform timeline delayed but Swiss announce intent to negotiate revised EU agreement||Tax - Luxembourg |
The proposal to revise the scope of the European Union Savings Directive (EUSD) failed to be approved at the ECOFIN meetings on 15 November and 10 December 2013.
|Tax alert||20140106January 2014|
|Worldwide Family Business Tax Guide (2013-2014)||We provide detailed information on tax issues impacting family businesses from 41 countries worldwide.||Tax guide||201312312013-2014|
|New Luxembourg government announces main aspects of its fiscal policy||Tax - Luxembourg |
On 2 December 2013, the newly composed Luxembourg government published its coalition program including components of its future fiscal policy.
|Tax alert||20131106December 2013|
|Shipping Industry Almanac: 2013||Our annual overview of the investment climate for shipping companies in more than 47 countries.||Tax guide||201312312013|
|European Commision proposes amendments to the Parent Subsidiary Directive||Tax - Global |
On 25 November 2013, the European Commission issued a proposal for an amendment to the EU Parent-Subsidiary Directive. The essential elements of the Proposal are (i) a “linking rule” that is supposed to deal with hybrid loan arrangements and (ii) a more detailed general anti-abuse rule (GAAR).
|Tax alert||20131106November 2013|
|New Tax Director Circular clarifies application of Net wealth Tax reduction||Tax - Luxembourg |
Circular I. Fort. n°47 dated 14 November 2013 clarifies certain aspects of Net Wealth Tax Reduction that need to be considered as from 2013 onwards.
|Tax alert||20131106November 2013|
|VAT: New Circular issued by the Luxembourg VAT Authorities confirming that risk management services for funds could be VAT exempt||VAT, GST and Other Sales Taxes - Luxembourg |
On 7th November 2013, the Luxembourg VAT Authorities issued a Circular (Circular n° 723 ter) confirming that risk management services for funds could be VAT exempt, including sub-contracted services if the criteria defined by the Court of Justice of the European Union are met.
|Tax alert||20130619November 2013|
|VAT on non-compliant purchase invoices||VAT, GST and Other Sales Taxes - Luxembourg |
The Court of Justice of the European Union has ruled in its Petroma Case that national tax authorities are entitled to refuse input tax deductions where the purchase invoice lacks required information, even when the missing information is obtained after the VAT audit.
|Tax alert||20130619November 2013|
|VAT: Le Credit Lyonnais: CJEU judgment: Partial exemption: Foreign branch income||VAT, GST and Other Sales Taxes - Luxembourg |
On 12 September 2013, the Court of Justice of the European Union (CJEU) has ruled in the case of Le Crédit Lyonnais (C-388/11) that a Member State may not authorise a company to take into account the turnover of a branch established in another Member State or in a third State.
|Tax alert||20130619September 2013|
|Draft Law on Patrimonial Foundations||Country Tax Advisory - Luxembourg |
The Luxembourg Minister of Finance has deposited on 22 July 2013 a draft law n° 6595 on patrimonial foundations.
|Tax alert||20130619August 2013|
|PPG Holdings - CJEU judgment on the VAT recovery of pension fund||VAT, GST & Other Sales Taxes - Luxembourg |
An employer can deduct VAT incurred on costs relating to a pension fund established as a separate legal entity.
|Tax alert||20130619July 2013|
|Tax policy and controversy: quarterly briefing||The volume and complexity of tax change continues. Alongside key global developments, we highlight corporate simplification, indirect taxes and cooperative compliance.||Brochure||20130716July 2013|
|EYe on Luxembourg tax: Luxembourg moving towards enhanced cooperation in taxation and exchange of information||Tax Policy and Controversy - Luxembourg |
Following Luxembourg’s adoption of a Law in March 2013 on administrative cooperation between EU Member States in the field of taxation, Luxembourg also announces automatic exchange of information on interest payments as of 2015.
|EYe on Luxembourg Tax||20130523May 2013|
|Luxembourg draft law proposes unconditional deferral of exit taxes||Cross Border Advisory - Luxembourg |
On 15 March 2013, the Luxembourg government submitted a draft law to the parliament amending the exit tax rules for individuals and companies. The draft law provides for an unconditional payment deferral of the capital gains tax until the actual disposal of the transferred assets or the transfer of tax residence outside of the European Economic Area (EEA), i.e., the other 26 Member States of the European Union as well as Iceland, Liechtenstein and Norway.
|Tax alert||20130507May 2013|
|Your bridge between Europe and China: Luxembourg||Cross Border Advisory - Luxembourg|
Expanding overseas is one of Chinese asset managers' highest short to medium term priorities. This publication sets out why Chinese asset managers should choose Luxembourg as their “hub” to distribute their funds to European and international investors.
|Europe’s CCCTB proposals||Tax Policy & Controversy - Global |
The proposal for a Common Consolidated Corporate Tax Base (CCCTB) will create winners and losers. Access all our materials related to the CCCTB proposals.
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